Privacy Policy
Introduction and Your Agreement to this Privacy Policy
Twyngo, Inc., and its affiliates (“Twyngo”, “us”, “our” or “we”) are dedicated to protecting the privacy rights of our users (“users”, “your”, or “you”). This Privacy Policy (the “Policy”) describes the ways we collect, store, use, and manage the information, including personal information, that you provide or we collect in connection with our website at www.twyngo.com (the “Site”) or any Twyngo game or application provided on other websites or other third party sources (collectively, the “Service”). Personal information can include, for example, an individual’s first and last name, address, telephone number, e-mail address or credit card number. Please note that the scope of this Privacy Policy is limited to information collected or received by Twyngo through your use of the Service. Twyngo is not responsible for the actions of third party people or companies, the content of their sites, the use of information you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those people or companies.
BY INSTALLING, USING OR OTHERWISE ACCESSING THE SERVICE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOTAGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE OR OTHERWISE ACCESS THE SERVICE. We may update this Policy from time to time. You are responsible for periodically reading this Policy. We will post all changes to this Policy on this page and the modified policy will specify its effective date.
Information Collected and Used
Our primary objective in collecting your information is to provide and enhance the Service and to enable you to easily navigate and enjoy the Service. For example, Twyngo may use your information to register your account, provide customer support, resolve disputes, collect fees, connect users, and notify you of updates to the game (or of other/new games) and special promotions.
iOS or Android Platforms
When you use any of the Pocket Gems games or applications, we automatically collect and record certain information such as your unique device ID, MAC address, hardware type, the version of your operating system (“OS”), your in-game activity, and your location (based on your Internet Protocol (“IP”) address). This information is useful to us for troubleshooting and helps us understand usage trends.
Twyngo uses country information to customize the user experience and promotions, enforce our terms of service, and make recommendations about user connections.
We may also give users the opportunity to opt-in to location-based services, which rely upon a device’s GPS coordinates. You may opt-out of these location services via the settings on your device. A user’s location may be used to suggest friends with whom they might want to connect, analyze usage trends or target certain promotions.
Some of our games or applications may permit a user to record his or her voice and share such recordings with an opponent in the context of such game or application. Twyngo may use these recordings and post them as well as the contents of your play sessions on Facebook on a publicly available page (and link your data with your opponent). Twyngo may store these recordings on its servers.
Google Server
Google is our application engine service provider. Any information provided through our applications is available to Google as part of Google providing this service. Google's Privacy policy can be reviewed here: http://www.google.com/intl/en/policies/privacy/
Localytics
Localytics is our data analytics service provider. Any information provided through our applications is available to Localytics as part of Localytics providing this service. Localytic's Privacy policy can be reviewed here: http://www.localytics.com/privacy-policy/
HockeyApp
HockeyApp is our crash analytics service provider. Any information provided through our applications is available to HockeyApp as part of HockeyApp providing this service. HockeyApp's Privacy policy can be reviewed here: http://hockeyapp.net/privacy/
Apple
Apple is our third party distributor and is our social games services provider. Any information provided through our applications is available to Apple as part of Apple providing this service. Apple's Privacy policy can be reviewed here: http://www.apple.com/privacy/
Pocket Gems
Pocket Gems is our third party distributor and is our publisher. Any information provided through our applications is available to Pocket Gems as part of Pocket Gems providing this service. Pocket Gem's Privacy policy can be reviewed here: http://pocketgems.com/privacy
Platforms/Third-Party Marketplaces
In the course of providing our Service on third party platforms/marketplaces, such as Apple’s App Store, the platforms/marketplaces may collect information about you or receive information from us in order for the platforms/marketplaces to provide or analyze their services. Please note that these platforms/marketplaces were developed and administered by people or companies not affiliated with or controlled by Twyngo and that Twyngo is not responsible for the actions of those people or companies. You should carefully review the terms of service and privacy policies of the platforms/third-party marketplaces that you use to access our Service
Facebook Connect
If you sign into the Service with Facebook Connect we will collect information that is visible via your Facebook account such as:
  1. you first and last name,
  2. Facebook ID,
  3. Profile Picture / URL, and
  4. list of Facebook Friends
This information will be primarily used for user registration and in social features, which may include friend-to-friend or user-to-user interaction, chat, voice or messaging functionality, public leaderboards, head-to-head competition and other similar features.
In-Game Dialog Boxes
When you register to play our games through the Service, we may ask whether you’d like to provide us with certain pieces of information, which could include: your email, username, phone number, gender, birthdate, home address, and address book. We will do this through in-game dialog boxes, which you may choose to skip. If you provide your email address in connection with a Twyngo game, the email address will be retained by Twyngo and we may use that email address to contact you about your gaming experience with Twyngo games and notify you about company news and promotions. We may also use part of your email address for friend-to-friend or user-to-user interaction and chat, voice or messaging functionality and other similar features. Your username may be used for social features in our games (e.g., presenting someone’s name on a message board). Your phone number may be used to help connect you with other users via our social networking system and for SMS notifications. Your gender and birthdate may be used to analyze user trends and target certain promotions. Your home address will be used if we have merchandise or other physical promotional materials we want to send to you. We may also request access to your address book to connect you to other players in the game.
If we begin offering our Service on a platform without an in-app purchase billing system, we may need to collect credit card and billing information.
Website
When you visit our Site, your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language and referring Web site addresses may be logged automatically. We may also collect information about your usage and activity, such as number of clicks, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time of this activity. We may use this information to monitor and analyze use of the Service.
Other Collection
We may also acquire information from you through
  1. your access and participation in message boards on the Service,
  2. your email of a question to our customer support,
  3. your purchase of a virtual product of any type
  4. your participation in surveys regarding the Service or
  5. your participation in a sweepstakes or contest through the Service.
Cookies
A cookie is a small data file that we transfer to your computer’s hard disk, generally to quickly identify a user’s computer and to "remember" things about the user’s visit, such as your preferences or a user name and password. The Service sends cookies to your computer when you access or view content of a Twyngo game. Information contained in a cookie may be linked to your personal information for purposes such as improving the quality of our Service, tailoring recommendations to your interests, and making the Service easier to use. You can disable cookies at any time, although you may not be able to access or use features of the Service.
We may feature advertisements served by third party advertising companies which deliver cookies to your computer so the ads you see can be tracked. Since the third party advertising companies tag your computer with a number, they will be able to recognize your computer each time they send you an advertisement. These advertisers may use information about your visits to our Service in order to provide advertisements about goods and services of interest to you.
Web Beacons
We may collect information using Web beacons. Web beacons or “gifs”, are electronic images that may be used on our Site or in our emails. We may use Web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon
Information for Opting-Out of Cookies and Web Beacons
You may click on the following link: http://www.networkadvertising.org/ (or such other URL as may be specified by us from time to time) for information on how to opt-out of the use of cookies or Web beacons.
Disclosure of Your Personal Information
Twyngo does not share your personal information except as approved by you or as described below:
  • With your consent, for example, when you agree to our sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies.
  • Twyngo may engage other companies and individuals to perform services on our behalf. Examples of these services include sending e-mails to you and analyzing data. While these agents and service providers may have access to your personal information in connection with the performance of services for Twyngo, they may not use such information for any purpose other than providing such services to us.
  • We may release your information as permitted by law or when we believe that release is appropriate to comply with the law; enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection.
  • Twyngo may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company.
  • We may share aggregate and anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.
Third Party Tools/Analytics
The Service may also contain third party tracking tools from third party service providers, which may enable these third parties to analyze our users’ information. These third parties may have access to your personal information in connection with the performance of services for Twyngo.
Offer Walls and Other Advertisements
You may see our games advertised in other applications. After clicking on one of these advertisements and installing our game, you will become a user of the Service. In order to prevent fraud and verify the installs, a unique device identifier may be shared with the advertiser.
Changing or Deleting your Information
You may contact us regarding any questions or comments regarding this Privacy Policy by emailing us at privacy@twyngo.com. If you completely delete all of your information, your account may become deactivated. You may opt-out of receiving promotional emails from us by following the instructions in those emails. If you opt-out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.
Under California law, California Residents who have an established business relationship with us may choose to opt out of the disclosure of personal information about them to third parties for such third parties’ direct marketing purposes. As detailed above, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, email privacy@twyngo.com .
Security
Twyngo has put in place industry standard technical and organizational measures designed to secure your information from accidental loss and from unauthorized access, use, alteration or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your personal information for improper purposes. Also please note that email and messaging systems are not considered secure, so we discourage you from sending us personal information through these mediums
International Transfer
We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Policy.
Contacting Us
If you have any questions about this Privacy Policy, please contact us at privacy@twyngo.com .